Select Committee on European Communities Second Report - Written Evidence

Memorandum by United Biscuits (UK) Limited

international food business operating in 21 countries. It has leading market positions in the UK, Continental Europe and is building its presence in Asia. It has 46 manufacturing sites world-wide and its products are available in over 90 countries. Over 20,000 are employed worldwide of which 16,000 are based in the UK.

  Today United Biscuits comprises two main operating divisions: McVitie's Group, the third largest biscuit company in the world and UK Foods Group which together manufacture, market and distribute a wide range of food products.

  Brands include household names in all product categories. Some famous brands include McVite's Digestive, Penguin, and Go Ahead! products, KP Nuts, Hula Hoops and Phileas Fogg snacks. Frozen and Chilled products include Linda McCartney meat-free products, Young's seafood, Ross Chip Shop range and San Marco pizzas. International brands include BN, Verkade, Fazer, and Gyori.


  2. UB recognises that genetic modification in agriculture could bring many benefits. These are widely acknowledged and include the following: plants with increased pest and disease resistance; reduction in the use of herbicides and pesticides; energy savings in farming; less soil erosion; crops with altered environmental tolerance; and food ingredients modified to improve processing.

  3. UB is committed to providing its consumers with products of consistent good quality and value which will appeal to consumers. Furthermore, product safety is an absolute priority. We will therefore use genetically modified ingredients, provided we are confident that they are approved safe and deliver benefit for society. We support the appropriate regulation of genetic modification in agriculture as essential to assure product safety and welcome the opportunity to express our views to the Select Committee on this subject.

  4. UB recognises that the proper regulation of genetic modification will play a critical part in addressing consumer concerns, through effective and scientifically based risk procedures. However, we stress that proper regulation alone cannot guarantee consumer acceptance of the new technology. That can only—and must—be achieved through a broader programme of education and information in which government, consumers and all parts of the food chain participate.


Contained use

  5. The control of research is well regulated in the UK; no significant safety issues have arisen in over 20 years of research and development. In fact the success of the UK system has led to it being used as a template by many other countries.

  6. We are aware that many scientists feel that the "Contained Use" regulations are unnecessarily restrictive given the exemplary safety record that exists.

  7. Another criticism is that the procedures underpinning the regulations are focused on micro-organisms and are thus inappropriate to the wider applications of genetic modification. This point was made in the 1993 Select Committee on Science and Technology Report on the Regulation of the UK Biotechnology industry and Global Competitiveness.

  8. We therefore support initiatives to revise the regulations to adopt a risk-based approach. However, in the current political climate any such changes would need to be presented very carefully to the public; failure to do so is likely to lead to further consumer backlash against the technology.

Release into the environment

  9. UB recognises that the system of controls in place is very well established and that the work of the Advisory Committee on Releases into the Environment (ACRE) is highly respected.

  10. The European Directive however has led to a number of problems. It has not been implemented consistently throughout the Member States and in practice procedural delays in getting approvals mean that researchers in Europe are at a significant competitive disadvantage compared with those in the US.

  11. We support initiatives to simplify the EU system. All procedures implementing the regulations should be transparent and timely. We also support the important role that consumer representatives can play in the decision making process; the EU system should mirror the UK system in this regard.

  12. We do not support current demands for a moratorium on field trials. The whole purpose of these trials is to investigate the safety of genetically modified crops and their impact on the environment. Stopping the trials would merely delay answering these vital questions.

  13. We are aware of the current debate regarding a proposed seven year monitoring period. Clearly consumer concerns about the safety of the technology cannot be ignored. Any regulations on monitoring should take account, as far as possible, of the need to protect the competitiveness of the UK and European industries. Also, the financial burden should not fall on industry alone.

  14. We recognise that some concerns relate to the cumulative effects of different applications of genetic modification in agriculture and that there are calls for an overview to be taken of the broader impact of the technology and its applications. We believe that there is merit in following this line of enquiry, that ACRE is the appropriate body to be given this remit and that its terms of reference should be amended accordingly.


  15. As a food manufacturer UB has considerable interest in the regulation of labelling of GM foods. We believe that the provision of information to consumers, including appropriate product labelling, is an essential element in achieving consumer acceptance of genetically modified foods.

  16. The fact that comprehensive EU labelling regulations were not agreed before genetically modified soya and maize appeared on the market is a major reason why these products—and indeed the whole principle of genetically modifying foods—have attracted extremely negative media coverage and increasing consumer hostility. The problems caused by the delays in agreeing these regulations, and before them the novel food regulations, should not be underestimated. Delays in implementation of regulations continue, neither a deminimus threshold nor list of exempt ingredients has been established and yet the regulation is to be law from 1 September 1998.

  17. We welcome the fact that EU regulations have finally been made on the labelling of GM soya and maize. Whilst these effectively reinterpret the concept of "substantial equivalence" set out in the novel food regulations, and thereby once more apply a different standard for genetically modified foods compared with other novel foods, we recognise that this was a pragmatic solution given the prevailing political environment.

  18. The vast majority of UB products including all of McVitie's biscuits, McVitie's Prepared Foods and KP snack products do not contain GM soya or maize material which we believe would trigger labelling. However, as stated above (point 16) there remains lack of clarity regarding what the trigger point is. Of the small number of UB products which we believe will trigger labelling under the above rules, most are already being labelled under the voluntary industry guidelines which were agreed in January 1998 in the absence of progress at EU level. We will progressively introduce labelling of the rest by the 1 September deadline.

  19. Whilst the EU regulations are an important step forwards it is imperative that the threshold levels for adventitious contamination are agreed and analytical methods developed as a priority so that the regulations can be properly enforced. It should be recognised that as detection methods become increasingly sensitive, threshold levels should not be reduced accordingly.


  20. As already mentioned we believe that both the well established UK system and now the EU regulations satisfactorily ensure the safety of genetically modified organisms. However, in some regards they put Europe at a disadvantage compared with the US and others.

  21. Ideally regulation of genetic modification in agriculture should be harmonised at an international level and a risk-based approach should be adopted. This should be achieved through the Codex Alimentarius Commission although the time that body takes to research decisions raises serious questions about its effectiveness.

16 July 1998

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